1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors service users and individual customers.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies to analyze website traffic and optimize your website experience. By accepting our use of cookies, your data will be aggregated with all other user data. .
1.4 In this policy, "we", "us" and "our" refer to Effective Advisors Limited, a company incorporated and registered in England and Wales with company number 10113729, our company website is www.effective-advisors.com. For more information about us, see Section 12.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer and/or your social media account. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
2.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
2.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, educational details and employment details. The source of the profile data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the profile data from the relevant social media account provider.
2.5 We may process information relating to our customer relationships ("customer relationship data"). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.
2.6 We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use ("service data"). The service data may, for example, include you as the decision make within your organisation, and/or as a supplier/user of certain services. The source of the service data is you and/or your employer and/or our services.
2.7 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
2.8 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website might generate the metadata associated with communications made using the website contact forms.
2.9 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3 Publications - We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
3.4 Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.5 Personalisation - We may process account data, service data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
3.6 Direct marketing - We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
3.7 Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.8 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.9 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.10 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.11 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to any affiliated companies insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.3 As a data controller, we retain all your personal information within the UK.
4.4 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for enabling the use of our services, and the proper administration of our website, services and business.
4.5 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
5.2 We may process your personal data in the UK for the purposes set out in this policy, and may permit our partners and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our partners and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
5.3. We may also transfer your personal data from the UK to third country (the United States, Canada, South Africa, New Zealand, India, Brazil, United Arab Emirates, Hong Kong, Singapore and/or Australia). If you are a resident in the EEA or the UK then these third countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law. Transfers to each of these countries will be protected by appropriate safeguards, namely, by using the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our partners. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 2 years following the date of the most recent contact between you and us, and for a maximum period of 6 years following that date;
(b) account data will be retained for a minimum period of 2 years following the date of closure of the relevant account, and for a maximum period of 6 years following that date;
(c) profile data will be retained for a minimum period of 2 years following the date of deletion of the profile by you, and for a maximum period of 6 years following that date;
(d) customer relationship data will be retained for a minimum period of 2 years following the date of termination of the relevant customer relationship and for a maximum period of 6 years following that date;
(e) service data will be retained for a minimum period of 2 years following the date of termination of the relevant contract, and for a maximum period of 6 years following that date;
(f) transaction data will be retained for a minimum period of 2 years following the date of the transaction, and for a maximum period of 6 years following that date;
(g) communication data will be retained for a minimum period of 2 years following the date of the communication in question, and for a maximum period of 6 years following that date;
(h) usage data will be retained for 2 years following the date of collection; and
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.5 When we have no ongoing legitimate business need to process your personal information, we will either delete or anonomyse such information, or, if that is not possible, for example, because your personal information has been stored in a backup archives), then we will securely store your personal information and isolate it in any further processing until deletion is possible.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security, and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to or from our website is at your own risk. You should only access the website within a secure environment.
7.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
8.5 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8.6 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement; in relation to complaints under UK data protection law, you should do so in the UK.
9. Third party websites
9.1 Our website might include hyperlinks to, and details of, third party websites.
9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Amendments
10.1 We may update this policy from time to time by publishing a new version on our website.
10.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
11. Our details
11.1 This website is owned and operated by Effective Advisors Limited.
11.2 We are registered in England and Wales under registration number 10113729, and our registered office is at 14 Old Queen Street, London, SW1H 9HP.
11.3 You can contact us by email, using the email address published on our website.
12. Data protection registration
12.1 We are registered as a data controller with the UK Information Commissioner's Office.
12.2 Our data protection registration number is ZA473314.
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